Compliance Blog

Written by JiJi Bahhur, Director of Regulatory Compliance

With less than 5 months before the fast approaching deadline (August 1, 2015), it is imperative that credit unions are making appropriate strides to comply with the CFPB’s Truth-in-Lending/Real Estate Settlement Procedures Act (TILA-RESPA) Integrated Mortgage Disclosure rule.

Of no surprise is that implementation of and compliance with the TILA-RESPA rule is one of NCUA's Top Supervisory Priorities for 2015.

“TILA-RESPA Integrated Disclosure Rule

On August 1, 2015, credit unions that originate residential mortgages will be required to comply with the Consumer Financial Protection Bureau’s (CFPB’s) TILA-RESPA Integrated Disclosure Rule. The rule requires loan originators to provide consumers with:

• A Loan Estimate form, which combines the initial Truth in Lending Act (TILA) disclosure and the Good Faith Estimate. The Loan Estimate form must be delivered or placed in the mail no later than the third business day after receiving a consumer’s mortgage application.
• A Closing Disclosure form, which combines the final TILA disclosure and the HUD-1 Settlement Statement. The Closing Disclosure form must be provided to the consumer at least three business days prior to consummation of the mortgage.

The new rule also imposes record retention requirements and restricts mortgage originators from imposing certain fees, providing estimates, or requiring consumers to verify information before providing consumers with a Loan Estimate form.

After the rule goes into effect, NCUA field staff will assess credit unions’ compliance with relevant provisions.”

If you or someone at your credit union has been charged with a role in compliance or implementation of TILA-RESPA, I would like to take a moment to say that you are not alone.  NAFCU’s Compliance Team has put an enormous amount of time and effort in to help prepare (NAFCU member and nonmember) credit unions for the compliance and implementation of the CFPB’s TILA-RESPA rule.  TILA-RESPA resources we have already made available include:

 

• TILA-RESPA Article Series, featured in NAFCU’s Compliance Monitor (NAFCU member log-in required):

TILA-RESPA Rule Overview

A Deep Dive into the Loan Estimate Disclosure: Requirements, Timing and Tolerances

Delving into the Closing Disclosure: Requirements, Timing, Delivery and More

Using Average Charges Over Actual Amount Received on the TILA-RESPA Closing Disclosure

Loan Estimates: Revisions and Corrections Under the TILA-RESPA Rule

Requirements for Providing Corrected Closing Disclosures under the TILA-RESPA Rule

Post-Consummation Notices under the TILA-RESPA Rule

 

• TILA-RESPA Blog Series, featured in NAFCU’s Compliance Blog (available to members and nonmembers)

 

• NAFCU-Hosted Webcasts on TILA-RESPA (available to members and nonmembers):          

TILA-RESPA Series: Part 1 – An Overview

TILA-RESPA: Difficult Issues and their Solutions

The 7^th Rule: Unintended Consequences of the New, “Simplified” Mortgage Disclosures

 

• New TILA-RESPA Appendix, featured in NAFCU’s 2015 Compliance GPS (available to members and nonmembers)

 

• NAFCU’s CFPB Mortgage Rules page, including a section dedicated solely to the TILA-RESPA Rule.  Resources include all resources mentioned above and (NAFCU member log-in required):                     

A summary of the final rule

A chart on the scope and applicability of the final rule

And more! 

 

And we’re not done!  NAFCU’s Compliance Team will continue to break down parts of the rule in its TILA-RESPA blog series and Compliance Monitor.  Also, coming soon, keep a look-out for a series of recorded modules dedicated solely to breaking down the TILA-RESPA rule (available to members and nonmembers).  And last, if you’d like to see a particular resource on TILA-RESPA, feel free to reach out with your ideas – we’re open to suggestions.

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Twin Sighting. This past weekend, my husband so kindly took the kids out on a lunch date so I could wrap some work up.  A couple hours after being out of the house, I received a call from my husband.  He said that a woman came up to him and said something along the lines of "Excuse me, are you JiJi's husband?" He responded that he was and asked the woman how she knew.  She stated, "I've never met your kids before, but I knew it was them because I see pictures of them on the compliance blog all the time!"  It turned out to be a local member who reads the blog and recognized the twins out in public.  Now only if my husband would have thought to snap a picture of the kids with her!